China Consults on Revised Hazardous Chemicals Operation Permit Rules

Key Takeaways

If adopted as proposed, the Draft Measures would replace the measures amended in 2015 and align the operation permit framework with China's Law on the Safety of Hazardous Chemicals, which took effect on May 1, 2026. The document remains a consultation draft, and no effective date has been specified.

For overseas suppliers, the immediate licensing obligation will generally fall on their China-registered operating entities, importers, distributors or warehousing partners. Overseas companies should nevertheless verify whether local supply-chain partners hold a permit covering the actual business model and chemicals involved.

• The consultation is open until October 22, 2026; the proposed requirements are not yet final.

• The draft identifies six business models, including operations without storage facilities and third-party warehousing operations.

• Proposed changes cover licensing authority, applicant conditions, electronic permit certificates, approval timeframes, renewals and penalties.

• Global suppliers should review the permits and operating models of their Chinese entities and local business partners.

What the Draft Measures Would Cover

According to the official consultation notice, the revision is intended to implement the Law on the Safety of Hazardous Chemicals and further standardize hazardous chemicals operation permits.

The Draft Measures would apply to business activities, including warehousing operations, involving hazardous chemicals listed in China's Catalogue of Hazardous Chemicals. Disposal of waste hazardous chemicals would remain subject to environmental-protection rules. Civil explosives, radioactive materials, nuclear substances, urban gas and hazardous chemicals used for national-defense research and production would remain outside the scope of the measures.

Six Proposed Business Models

The Draft Measures list six forms of hazardous chemicals business activity:

1. Operations without storage facilities;

2. Hazardous chemicals stores;

3. Motor-fuel stations (gas stations);

4. Operations with storage that do not constitute a major hazard installation;

5. Operations with storage that constitute a major hazard installation; and

6. Warehousing operations.

A hazardous chemicals warehousing operator is defined as an enterprise that uses hazardous chemicals storage facilities or sites to provide storage and turnover services for other entities. The clearer classification would help companies determine which licensing authority, applicant conditions and supporting materials may apply to their actual operations.

Key Proposed Changes and Business Impact

Licensing Authority and Entry Conditions

The Draft Measures would divide permit responsibility between prefecture-level municipal and county-level licensing authorities. Municipal-level authorities would be responsible for enterprises operating highly toxic chemicals or explosives-precursor hazardous chemicals, specified central enterprises and their subsidiaries, and storage operations involving major hazard installations. These responsibilities could not be delegated to county-level authorities.

All applicants would need to be legally registered as enterprises. Proposed baseline conditions include compliant non-residential business premises, trained employees, dedicated safety-production management personnel, safety-management systems and job operating procedures, and an emergency response plan supported by necessary emergency equipment and resources.

Storage-related applicants would face additional requirements. Depending on the storage model, these may include planned storage locations, safety evaluations, professional qualifications for responsible personnel, major hazard monitoring and early-warning systems, and gas detection and alarm controls. An emergency response plan filing record would be among the additional application materials for businesses storing hazardous chemicals.

Electronic Permits Applications and Renewals

• Electronic hazardous chemicals operation permit certificates would have the same legal effect as paper certificates.

• Licensing authorities would use the hazardous chemicals business safety regulatory system to assign permit numbers.

• A licensing authority would generally decide whether to grant a permit within 20 working days after accepting an application. Time used for on-site verification, rectification or revision of application materials would not be included in that period.

• Companies would need to apply for renewal at least three months before the permit expires.

• A business operating without storage facilities that changes its business premises would need to submit a new permit application. Changes to storage locations, business models or licensed scope would also trigger reapplication under the draft.

What Global Businesses Should Do Now

1. Confirm which Chinese entity holds or needs the permit and identify the actual operating model, including whether any storage or third-party warehousing is involved.

2. Compare the permit scope with the hazardous chemicals actually sold, distributed or stored, as well as the activities performed at each location.

3. Review business premises, personnel qualifications, training records, safety-management systems and job operating procedures against the proposed conditions.

4. Check whether the emergency response plan and emergency resources reflect actual operations and whether filing is required for the applicable storage model.

5. Verify the permit status of suppliers, distributors and warehousing partners, particularly before purchasing or transferring hazardous chemicals.

6. Monitor the final Measures and local implementation requirements before changing application or renewal procedures.

How REACH24H Can Support

REACH24H supports companies with:

• Hazardous chemicals operation permit applications for operations without storage facilities;

• Preparation of safety-production rules, management systems and job operating procedures; and

• Preparation of emergency response plans and filing support, where applicable.

For further information, visit REACH24H's China Hazardous Chemicals Operation Permit service page.

Recommended Reading

• China's Hazardous Chemicals Safety Law

• China Hazardous Chemical Registration

Official References

• MEM consultation notice

• Draft Measures for the Administration of Hazardous Chemicals Operation Permits